Notes regarding this webpage:
This webpage is regularly updated with the most current advice regarding the impact of COVID-19 on the Church of Scotland Insurance Services Church Insurance Scheme. All articles are shown below in chronological order with the most recent at the top. This allows access to the previous advice provided should it be required.
All our staff continue to work from home but their contact information including direct dial numbers are shown on the contact page of this website.
Advice from the Church of Scotland regarding managing the risk from COVID-19 can be found at https://churchofscotland.org.uk/resources/covid-19-coronavirus-advice
Clarification in the article below. (21st July 2020)
Following receipt of correspondance from congregations Aviva have clarified their position confirming, as noted in bold in the article below, that congregations must advise that they are able to comply with the clause providing full cover on properties that remain unoccupied as of 5th August 2020 to obtain the benefit of the additional cover.
If therefore you are contacting COSIS to advise that your church will not be open as of the 5th of August please also confirm that it is your intention to comply with the terms of the clause wording shown in the article below.
Impact of the relaxation of Scottish Government COVID-19 Regulations on Insurance of Church Property and Key Dates for the return to the policy definition of unoccupancy (14th July 2020)
This document will provide an outline of changes to the insurance cover available for Church of Scotland properties as the Scottish Government Regulations are relaxed in respect of places of worship following temporarily closed due to the COVID-19 pandemic.
Aviva, the primary insurer on The Church of Scotland Insurance Service’s (COSIS) Church insurance scheme, have adopted a supportive stance during the COVID-19 crisis by agreeing that property temporarily closed solely due to the pandemic would not be deemed by them to be unoccupied. This agreement was subject to individual policyholders carrying out appropriate risk assessments and implementing reasonable steps to manage the change in risk. The current and final extension of that approach will expire on the 5th August, several weeks after the transition to Phase 3 of the Scottish Government’s “route map” to exit lockdown.
Insurers recognise that the pace of change at which church premises will move towards full use (services of worship, weddings, funerals, etc.) will vary by congregation. During that transitional phase, they have accepted that if the premises are open to the public for worship, even in a restricted way such as regular private prayer, the premises will be deemed to be “occupied” for the purposes of your insurance.
What might change after the 5th August? Will churches that don’t reopen be considered Unoccupied then?
As you know, the use of church premises was curtailed due to “lock-down”. The insurer’s response was to support policyholders by ameliorating the standard terms and conditions that would apply to unoccupied premises under the policy. As soon as churches are permitted to re-open insurers will, not unreasonably, look to return to their standard policy terms and conditions.
Recognising, however, that the pace at which congregations will be able to progress towards full use of their premises may differ from one to another, insurers have maintained their supportive approach, but with an important change in how they define unoccupancy.
From 5th of August where a property will not be open for use it will be deemed unoccupied. If this is the case you must advise COSIS immediately as you have a duty to disclosure an unoccupied property to your insurer. Once we know about this, we will be able to agree a further extension of full cover to a date no later than 23rd September 2020. This extension of cover will be strictly subject to your compliance with the clause noted below which will require to be endorsed onto your policy. If you wish to benefit from this clause you must confirm to us that you have made adequate provision to deal with its requirements otherwise the standard terms of your policy will apply and your insurer may not be obligation to settle your claim on a full cover basis.
Covid 19 - Temporarily Unoccupied Premises Condition
If in relation to any claim for Damage while The Premises are Unoccupied, you have failed to fulfil any of the following conditions, You will lose Your right to indemnity or payment for that claim.
(1) carry out internal and external inspections of the buildings as least every seven days and
a) maintain a weekly log of such inspections
b) immediately repair, or arrange to repair, any defects found
i) in the buildings, including removal of graffiti
ii) in the security or alarm or fire protection installations.
(2) remove all waste either within or outside the buildings, from the Premises.
(3) securely lock all external doors, close and secure all windows
Please note that in addition to weekly inspection you must keep a log of your visits noting any damage
05th August 2020 - Buildings undergoing contract works
If your building will not re-open after the 5th August solely because it is undergoing contract works please contact COSIS to ensure the correct cover(s) are in place – these should be no different to those that would normally have applied prior to “lock-down”.
05th August 2020 – Other types of occupation
If a number of your buildings are being used but not as places of worship, for example by local schools or as a food bank, then it is likely that those particular buildings will be considered occupied. Please call COSIS to discuss if you have any doubts in respect of your congregation’s individual circumstances.
23rd September 2020 - Resumption of normal policy terms and conditions
After the 23rd of September standard policy terms and conditions will resume on all cases. It is almost certain therefore that any church which has not re-opened to provide, at the very least, regular private prayer will now be considered unoccupied under the terms of your policy. As soon as you are aware that this might be a possibility you should get in touch with the COSIS team to discuss your circumstances as you have a duty to disclose unoccupancy to your insurer. Should your property be deemed unoccupied it is likely that restrictions in cover and inspection requirements will apply. In addition depending on the proposed schedule for re-opening there could be additional premium charges to meet.
05th August - Properties that may never reopen
If for some reason you believe that your property may not re-open for worship, please let COSIS know so that we can review and update your insurance arrangements as necessary. This is an example of a material change in insurance risk and you have a duty to disclose this to your insurer. It is likely that restrictions in cover and inspection requirements will apply and additional premiums could be charged.
COVID-19, Liability Insurance and Risk Management
COSIS has received a number of enquiries asking whether there is cover for liabilities relating to COVID-19 under the policy. It should be noted that there are no specific changes to the Employers Liability or Public Liability covers in respect of COVID-19 but there is an expectation that congregations will act reasonably to manage their risk within the Scottish Government’s Regulations and current guidelines. The Church of Scotland has issued a large amount of advice that should assist you in this. (See below)
Risk Management Advice – COVID-19
It has been impossible for insurers to provide each individual policyholder with specific risk management advice. Instead, given the scale of the challenge, they have provide broad risk management information across a range of industries/sectors. One of the key messages was that policyholders should conduct risk assessments, as appropriate to their individual circumstances, allowing them to manage risk within the spirit of the Scottish Government’s Regulations and guidelines.
COVID-19 risk management information has been issued by the Church of Scotland for the benefit of Kirk Sessions and congregations. It has been compiled from information provided by insurers as well as information from Government and the Health and Safety Executive. It is regularly reviewed and update. This information is available on the Church of Scotland’s website at…
12th June Update - Extension of period of grace on unoccupancy due to COVID 19
The 90 day period of grace provided by Aviva, during which they agreed not to consider buildings closed purely due to the impact of COVID 19, is due to end shortly. We have however now been advised that they have extended this period for another 45 days. The period of grace on unoccupancy should therefore not come to an end until several weeks into Phase Three of the Scottish Government’s COVID – 19 Route Map, assuming it proceeds with no set-backs or interruptions. See link to Aviva announcement below.
The Church of Scotland has also issued its guidance on the re-opening of church buildings following the COVID – 19 lockdown and this can be found at the link below.
Generally speaking insurers are not looking to become involved in the detail of re-opening buildings as long as the process is being carried out in line with the Government’s COVID 19 regulations and with appropriate health and safety processes and risk assessments in place. There are however a number of things that congregations should consider in respect of their insurance when deciding how best to manage their risk during this period.
- The position is fluid and could change between now and the end of the current extension. Please continue to monitor both this web page and the Church of Scotland website for the most up to date information.
- Aviva have indicated that they will take a positive view when considering whether a church building might be deemed to be occupied. Any regular service, including online broadcasts, funerals, and public prayer, is likely to be sufficient to allow the building to be considered to be in operation again.
- As a rule of thumb, for insurance purposes, having some form of service once a month will generally be sufficient for a property to be considered occupied. Whether you are able to open your building will however be dictated by your specific circumstances and should be governed by the procedures outlined in the Church guidelines linked above.
- Some congregations will know that their church buildings will continue to remain closed for a significant period even when they are allowed to re-open to under the Scottish Government’s regulations. If your property will remain closed beyond the 1st of August you must contact COSIS as Aviva’s announcement makes it clear that it is unlikely that there will be a further extension. Your property will therefore be considered unoccupied and might suffer significant restrictions in cover and increased premiums. Please note that occupancy is material information and there is an obligation to declare this to your insurer.
- If your property is at risk of being considered unoccupied at the start of August then you will require to carry out inspections once a week to make sure that all is well and there is no damage to the property. A note of these visits should be retained along with an indication that no damage or other issue has been identified. Most congregations are currently carrying out some kind of inspection but you may need to increase the frequency depending on the current system you have in place.
- Whilst, as noted above, insurers are generally happy for congregations to proceed within the regulations if you have an issue specific to your congregation that is material to your insurance risk please contact the COSIS team to discuss whether it needs to be referred to Aviva.
I hope this provides some clarity on the position on unoccupancy of church buildings in the run up to churches being able to re-open but suggest you monitor this website for updates. In the meantime if you want to discuss any aspect of your insurance you will find the direct dial numbers for all COSIS staff on the “Contacts” section of our website.
Overview and impact on COSIS servicing arrangements (Original article)
As I’m sure you are aware we are currently in the midst of a challenge from COVID 19 that is unprecedented in living memory. Whilst the insurance industry, like many others, had detailed business continuity plans no one imagined a shutdown on this scale with the need to move much of the industry to remote working at short notice. To add to the insurance industry’s difficulties it finds itself protecting a vast range of property no longer occupied or used as described when Insurers accepted the risk and calculated a premium. This will be an important consideration when trying to understand and interpret insurer's communications during this crises.
Insurers have had to consider how they might reasonably deal with the changes forced upon their clients by the governments response to COVID 19 but prior to the announcement of the “lockdown” the pace of change had been such that advice written one day had become obsolete by the next. Hopefully however we will now have a short window of stability that will allow this advice to remain valid over the next few weeks.
This web-page is primarily intended to provide guidance on managing and protecting church property from an insurance stand point. The Church of Scotland has however issued general advice regarding COVID 19 as well as specific information regarding the management of your property which can be found at the links below.
Managing the change in your Property Risk
The most common question COSIS staff are being asked is what the requirements are for managing church property closed directly following recent government advice to avoid public gatherings and subsequent lockdown. Aviva have now agreed to extend the period before an active church, closed following the lockdown, is deemed unoccupied from 45 to 90 days. This is very helpful as, for a significant period, it avoids additional premiums relating to unoccupancy and the associated formal requirement for inspection. It is important to note however that congregations still have a Duty of Care under their insurance policy to
- maintain their Buildings, Contents and Equipment in a satisfactory state of repair
- take all reasonable steps to prevent damage to the Property Insured
- take all reasonable steps to prevent accident or injury to any person
- comply with all legal requirements and safety regulations and conduct their business in a lawful manner.
It is impossible to be prescriptive about what must be done to meet this duty of care as each church has its own individual circumstances. Aviva have suggested that congregations should carryout risk assessments to consider the changing risk/lack of supervision. As a minimum however inspection both internally and extenally on a regular basis and both before and after an increased risk, such as extreme weather, would seem like an appropriate base level.
An Important Notice regarding your policy can be viewed here that summarises the areas that Aviva think you should be considering for action.
Property where there are existing Inspection or Management requirements
Please note that the text above only applies only to property which has closed as a direct response to the Government’s request to avoid public gatherings. Where a property was already subject to an agreed inspection or other risk management requirement this will remain in place without specific referral and agreement to the contrary. In general the requirement that these properties are inspected both externally and internally is unlikely to be waived.
Loss of Income from Letting Churches and Halls
In addition to concern over risk to the building many congregations will be wondering about the position regarding loss of earnings from letting their hall. Unfortunately there is no cover under our church policy or the vast majority of commercial insurance policies. The only cover for loss of revenue due to disease relates to named diseases specified in the policy wording where the risk can, to a degree be statistically quantified, and an appropriate premium charged.
Aviva’s statement on this issue is shown below
Does Aviva's Business Interruption cover COVID-19?
The Government announcement on Tuesday evening (17 March) concerning both ours and other insurers' position with regards to Business Interruption has caused some confusion and as a result, we've received a number of queries from both you and your clients.
To clarify, COVID-19 is not covered under our standard Business Interruption policies and, as the chancellor said, you cannot retrospectively change insurance contracts at this time without threatening the future of the insurance industry.
Our Business Interruption cover is based on a specified list of diseases and has been since the SARS outbreak in 2003. These policies exclude Business Interruption due to new and emerging diseases, like COVID-19.
Our policy wording clearly identifies the diseases we offer cover for and, in addition, highlights that new and emerging diseases like COVID-19 are not covered.
For information both you and your clients may find useful, please see details of the additional support the Government is provided on